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2011 (3) TMI 260 - AT - Service TaxRefund - 100% EOU - Engineering Design Services - Rule 3 of the Export of Services Rules, 2005 - Notification No. 12/2005-ST, dated 19-4-2005 - it is clear that the assessees are rendering technical assistance in mechanical engineering and automobile engineering - The assessees have also obtained opinions from the Indian Institute of Technology, Chennai, Anna University, Chennai, Software Technology Park of India that the service rendered by them is not “software Engineering Service” and although these opinions were not placed before the Commissioner who passed the impugned order dated 23-7-2007, they were produced prior to the passing of the subsequent impugned orders, but not considered - Decided in the favour of the assessee by way of remand.
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